The EU wants the batteries powering Europe’s phones, cars and energy storage to last longer, contain more recycled materials and carry more information about where they came from. Its new Batteries Regulation is designed to make that happen. But with the next major requirements less than six months away, companies are still waiting for some of the details they need to prepare.
The EU Batteries Regulation, adopted in 2023, is set to overhaul how batteries are designed, produced, used and disposed of. It covers everything from safety and performance to carbon footprints, recycled content and the collection of used batteries.
The basic idea is to keep batteries and the materials inside them in use for longer. That means making some batteries easier to replace, requiring manufacturers to take greater responsibility for batteries once they become waste and, eventually, introducing a digital record containing information about a battery’s origins, characteristics and sustainability.
“Manufacturers require a minimum transitional period of two years to redesign and adapt to the manufacture of devices if a requested exemption is rejected.”
— Euralarm
But the regulation is not arriving all at once. Different rules apply to different types of batteries at different times, while some deadlines depend on further legislation from the European Commission.
As the next major deadline approaches in February 2027, companies face an awkward reality: the clock is ticking, but parts of the rulebook are still being filled in.
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A product design problem
One of the clearest examples is the requirement that, from 18 February 2027, consumers should be able to remove and replace portable batteries using commercially available tools rather than specialised or proprietary equipment. The aim is to prevent products from being discarded simply because their battery has reached the end of its life.
For manufacturers, however, that can become a product-design problem. Batteries that are glued or sealed inside a device, for example, may be difficult to replace without redesigning the product.
The regulation also divides batteries into different categories — including portable, electric vehicle, light means of transport and industrial batteries — with different requirements and deadlines for each. That makes determining which category a battery falls into an important first step for companies working out which obligations apply to them.
Brussels is still filling in the details
The bigger problem is that companies have not always known exactly which products will be covered. The Regulation allows exemptions for products where making batteries removable by consumers could create safety problems or undermine a product’s functioning. Medical devices and so-called “wet appliances”, such as electric toothbrushes and water flossers, are already covered by exemptions.
But the Commission has continued to expand the list. In April, it launched a public consultation on six additional categories of products that could be exempted from the general requirement. On 14 July, the Commission adopted a delegated act adding those categories, including wearable devices such as smartwatches and fitness trackers, electric toys and certain equipment for use in potentially explosive environments.
While the main deadline has been known for years, some manufacturers have only recently received greater clarity on whether their products would need to comply with the removability requirement at all.
Euralarm, which represents the fire safety and security industry, has warned that uncertainty around pending exemption requests could leave manufacturers with little time to adapt. Of the 81 submitted in 2025, decisions on some were still pending in April.
“Manufacturers require a minimum transitional period of two years to redesign and adapt to the manufacture of devices if a requested exemption is rejected,” the group said, warning that without such an extension, companies face “significant legal uncertainty and the risk of disproportionate economic burden.”
The next challenge: a digital passport
February 2027 will bring another major change. From 18 February, electric vehicle batteries, batteries used in light means of transport such as e-bikes and e-scooters, and industrial batteries with a capacity above 2 kWh placed on the EU market will need a Digital Battery Passport.
The passport is intended to make information about batteries more accessible throughout their lifecycle. It can include information related to the battery’s characteristics, performance and sustainability, allowing different actors in the value chain to access relevant data.
The Commission has been working to give companies a clearer picture of what that will mean in practice. This month, it published updated guidance bringing together 71 data points and showing whether they are mandatory, optional or only applicable in certain circumstances for different categories of batteries.
The guidance is meant to help manufacturers, importers and others responsible for providing information through the passport prepare their data systems and reporting processes. But compliance will not necessarily mean simply collecting information from a company’s own operations. It could also require obtaining and verifying data from across an international supply chain.
A system that has to work beyond Europe
That problem was also recently voiced by various researchers from Leiden University. The EU’s battery rules cover issues such as carbon footprints, circularity and the responsible sourcing of raw materials. But the researchers argue that setting requirements is only part of the challenge: Europe also needs a system capable of verifying compliance across very different production environments.
“Most stages of battery production take place outside the EU,” said Edgar Hertwich, one of the researchers. “If the EU wants to reduce emissions, it must ensure that global supply chains are both willing and able to work with its accounting rules.”
In other words, the regulation may apply to batteries placed on the European market, but much of the information needed to demonstrate compliance may have to come from far beyond the EU’s borders.
A timetable in flux
The Commission has already shown a willingness to adjust the timetable when companies face difficulties preparing for new obligations. Battery due diligence requirements, originally scheduled to apply from August 2025, were postponed by two years to August 2027 as part of a wider Commission push to simplify sustainability and reporting requirements.
Other deadlines, however, remain unchanged.
For companies, the challenge is therefore not just knowing when the rules will apply. It is knowing which requirements are already fixed, which depend on further delegated or implementing acts, and whether there will be enough time to adapt when the details finally arrive.
